mmpc - National Indian Health Board

November 12, 2012
Centers for Medicare and Medicaid Services
Office of Strategic Operations and Regulatory Affairs
Division of Regulation Development
Department of Health and Human Services
Attention CMS-10445 / OCN: 0938-New
Room C4-26-05
7500 Security Boulevard
Baltimore, MD 21244-1850
Submitted via regulations.gov
RE: Comments of CMS-10445; Survey regarding the Medicare Advantage Quality Bonus Payment
Demonstration
I write on behalf of the National Indian Health Board (NIHB) 1 , to the Centers for Medicare and Medicaid
Services (CMS) regarding the request for comments on CMS-10445 / OCN 0938-New pertaining to the
Paperwork Reduction Act (PRA) Notice on the survey of Medicare Advantage plans regarding the
Medicare Advantage Bonus Payment Demonstration published in the Federal Register on September 17,
2012 (Request for Comments). 2 We appreciate the opportunity to comment on the proposed survey.
We provide below a limited set of recommended additions to the survey.
Background
CMS-10445 requests comments on the survey to be conducted of Medicare Advantage Organizations
(MAOs) as part of an assessment of the MA Bonus Payment Demonstration.
Under the Affordable Care Act (ACA), beginning in 2012, all plans earning four or five stars in Medicare’s
Star Rating program will receive quality bonus payments (QBPs). As an extension of this legislation, CMS
launched the Medicare Advantage Quality Bonus Payment Demonstration, which accelerates the phasein
of QBPs by extending bonus payments to three-star plans and eliminating the cap on blended county
1 Established 40 years ago, NIHB is an inter-Tribal organization that advocates on behalf of Tribal governments for the provision
of quality health care to all American Indians and Alaska Natives. NIHB is governed by a Board of Directors consisting of a
representative from each of the twelve Indian Health Service (“IHS”) Areas. Each Area Health Board elects a representative to
sit on the NIHB Board of Directors. In areas where there is no Area Health Board, Tribal governments choose a representative
who communicates policy information and concerns of the Tribes in that area with NIHB. Whether Tribes operate their entire
health care program through contracts or compacts with IHS under Public Law 93-638, the Indian Self-Determination and
Education Assistance Act (“ISDEAA”), or continue to also rely on IHS for delivery of some, or even most, of their health care,
NIHB is their advocate
2 77 Federal Register 57090, Comment Request, Medicare Advantage Quality Bonus Payment Demonstration, CMS-10445,
September 17, 2012 (http://www.gpo.gov/fdsys/pkg/FR-2012-09-17/html/2012-22726.htm)
Draft NIHB Comments on CMS-10445 Page 1 of 3